Privacy Policy

1.1 I am committed to safeguarding the privacy of my website visitors, service users and individual customers.

1.2 This policy applies where I are acting as a data controller with respect to the personal data of such persons; in other words, where I determine the purposes and means of the processing of that personal data.

1.3 My website incorporates privacy controls which affect how I will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the collection, sharing and publication of your personal data.

1.4 I use cookies on my website. Insofar as those cookies are not strictly necessary for the provision of my website and services, I will ask you to consent to my use of cookies when you first visit my website.

1.5 In this policy, “I”, “me” and “my” refer to Paula Codrington c/o Paula Deegan Photography. For more information about me, see Section 13.

2.1 In this Section 2 I have set out the general categories of personal data that I process and, in the case of personal data that I did not obtain directly from you, information about the source and specific categories of that data.

2.2 I may process data enabling me to get in touch with you (“contact data“).[ The contact data may include [your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you.

2.3 I may process your website user account data (“account data“). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by my website.

2.4 I may process information relating to transactions, including purchases of goods and/or services, that you enter into with me and/or through my website (“transaction data“). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or my payment services provider.

2.5 I may process information contained in or relating to any communication that you send to me or that I send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. My website will generate the metadata associated with communications made using the website contact forms.

2.6 I may process data about your use of my website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is my analytics tracking system.

3.1 In this Section 3, I have set out the purposes for which I may process personal data and the legal bases of the processing.

3.2 Operations – I may process your personal data for the purposes of operating my website, the processing and fulfilment of orders, providing my services, supplying my goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is my legitimate interests, namely the proper administration of my website, services and business OR the performance of a contract between you and me and/or taking steps, at your request, to enter into such a contract.

3.3 Publications – I may process account data for the purposes of publishing such data on my website and elsewhere through my services in accordance with your express instructions. The legal basis for this processing is consent OR my legitimate interests, namely the publication of content in the ordinary course of my operations OR the performance of a contract between you and me and/or taking steps, at your request, to enter into such a contract.

3.4 Relationships and communications – I may process contact data, account data, transaction data and/or communication data for [the purposes of managing my relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, and/or telephone, providing support services and compliant handling. The legal basis for this processing is my legitimate interests, namely communications with my website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of my website, services and business.

3.5 Direct marketing – I may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent OR my legitimate interests, namely promoting my business and communicating marketing messages and offers to my website visitors and service users.

3.6 Research and analysis – I may process usage data and/or transaction data for [the purposes of researching and analysing the use of my website and services, as well as researching and analysing other interactions with my business. The legal basis for this processing is consent OR my legitimate interests, namely monitoring, supporting, improving and securing my website, services and business generally.

3.7 Record keeping – I may process your personal data for the purposes of creating and maintaining my databases, back-up copies of my databases and my business records generally. The legal basis for this processing is my legitimate interests, namely ensuring that I have access to all the information I need to properly and efficiently run my business in accordance with this policy.

3.8 Security – I may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is my legitimate interests, namely the protection of my website, services and business, and the protection of others.

3.9 Insurance and risk management – I may process your personal data where necessary for [the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is my legitimate interests, namely [the proper protection of my business against risks.

3.10 Legal claims – I may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is my legitimate interests, namely [the protection and assertion of my legal rights, your legal rights and the legal rights of others.

3.11 Legal compliance and vital interests – I may also process your personal data where such processing is necessary for compliance with a legal obligation to which I am subject or in order to protect your vital interests or the vital interests of another natural person.

4.1 I may disclose your personal data to my insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

4.2 Your personal data will be held in my website database.

4.3 Financial transactions relating to my website and services are OR may be handled by my payment services providers Paypal. I will share transaction data with my payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.paypal.com/.

4.5 In addition to the specific disclosures of personal data set out in this Section 4, I may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which I are subject, or in order to protect your vital interests or the vital interests of another natural person. I may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.1 In this Section 5, I provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area.

5.2 The hosting facilities for my website are situated in England. The competent data protection authorities have made an “adequacy decision” with respect to the UK data protection law.

5.3 You acknowledge that personal data that you submit for publication through my website or services may be available, via the internet, around the world. I cannot prevent the use (or misuse) of such personal data by others.

6.1 This Section 6 sets out my data retention policies and procedures, which are designed to help ensure that I comply with my legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that I process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 I will retain your personal data as follows:

(a) contact data will be retained for a minimum period of six months following the date of the most recent contact between you and me, and for a maximum period of 26 months following that date;

(b) account data will be retained for a minimum period of six following the date of closure of the relevant account, and for a maximum period of 26 months following that date;

(c) transaction data will be retained for a minimum period of 14 days following the date of the transaction, and for a maximum period of 12 months following that date;

(d) communication data will be retained for a minimum period of six months following the date of the communication in question, and for a maximum period of 26 months following that date;

(e) usage data will be retained for six months following the date of collection; and for a maximum period of 26 months.

6.4 Notwithstanding the other provisions of this Section 6, I may retain your personal data where such retention is necessary for compliance with a legal obligation to which I are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.1 In this Section 7, I have listed the rights that you have under data protection law.

7.2 Your principal rights under data protection law are:

(a) the right to access – you can ask for copies of your personal data;

(b) the right to rectification – you can ask me to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure – you can ask me to erase your personal data;

(d) the right to restrict processing – you can ask me to restrict the processing of your personal data;

(e) the right to object to processing – you can object to the processing of your personal data;

(f) the right to data portability – you can ask that I transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority – you can complain about my processing of your personal data; and

(h) the right to withdraw consent – to the extent that the legal basis of my processing of your personal data is consent, you can withdraw that consent.

7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

7.4 You may exercise any of your rights in relation to your personal data by written notice to me, using the contact details set out below.

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3 Cookies may not contain any information that personally identifies a user, but personal data that I store about you may be linked to the information stored in and obtained from cookies.

9.1 I use cookies for the following purposes:

(a) authentication and status – I use cookies to identify you when you visit my website and as you navigate my website, and to help me determine if you are logged into my website (cookies used for this purpose are: identify cookies);

(b) shopping cart – I use cookies to maintain the state of your shopping cart as you navigate my website (cookies used for this purpose are: identify cookies);

(c) personalisation – I use cookies to store information about your preferences and to personalise my website for you (cookies used for this purpose are: identify cookies);

(d) security – I use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect my website and services generally (cookies used for this purpose are: identify cookies);

(e) analysis – I use cookies to help me to analyse the use and performance of my website and services (cookies used for this purpose are: identify cookies); and

(f) cookie consent – I use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: identify cookies).

10.1 My service providers use cookies and those cookies may be stored on your computer when you visit my website.

10.2 I use Google Analytics. Google Analytics gathers information about the use of my website by means of cookies. The information gathered is used to create reports about the use of my website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy. The relevant cookies are: identify cookies.

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you will not be able to use all the features on my website.

12.1 I may update this policy from time to time by publishing a new version on my website.

12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

12.3 I may notify you of significant changes to this policy by displaying a message on my homepage.

13.1 This website is owned and operated by Paula Codrington c/o Paula Deegan Photography.

13.2 My registered office is in Albert Road, Epsom, Surrey KT17 4EL

13.3 My principal place of business is as above.

13.4 You can contact me:

(a) using my website contact form;

(b) by telephone, on the contact number published on my website; or

(d) by email, using the email address published on my website.

14.1 My data protection officer’s contact details are: as above.